The Vaccines for Children Program makes sure kids whose parents can’t afford vaccines can still get their kids vaccinated. Funding for VFC comes via the CDC, who buys vaccines at a discount and distributes them to states. States distribute them to physicians’ offices & clinics that take part in the VFC program. ADHS manages the VFC program in our state.
The Arizona Partnership for Immunizations held a “Vaccine Congress” meeting last week to discuss potential solutions to major problems that have developed in Arizona’s Vaccines for Children program over the last 8 years.
The central problem discussed was the declining provider participation in the VFC program: Arizona lost 50% of its VFC providers during the Ducey administration – going from 1,200 to 600… reducing access to vaccine, lowering childhood vaccination rates and harming overall AHCCCS network capacity.
Why the decline? Anecdotally, providers who left VFC over the last few years say they quit because of the administrative hassles imposed on them by the state over the last 8 years (ADHS not AHCCCS).
At the top of the list of grievances is ADHS’ punitive practice (during Director Christ/Herrington’s tenure) of financially punishing providers with wastage rates over 5% making participation financially difficult (see this letter to AZAAP members regarding ADHS’ policy).
Arizona now only has 6 VFC providers per 10,000 Medicaid eligible kids, while the national average is 24 providers per 10,000 Medicaid kids… meaning Arizona only has a quarter of the number of VFC providers per Medicaid kid compared with the national average.
For many years, clinics and doctors’ offices were required to be enrolled as a VFC provider to take part in the Medicaid (AHCCCS) program. The enormous drop in VFC participation was narrowing AHCCCS’ network so much that a couple of years ago AHCCCS had to remove that requirement as long as the provider refers the child to somewhere that’s still providing vaccines – often the county health departments. That has put an enormous strain on both families and county health departments and has been contributing to declining vaccination rates.
To shed more light on the causes of plummeting participation and to identify solutions the Arizona Partnership for Immunizations hired the OMNI Institute to explore why so many providers have quit VFC.
OMNI’s report has 3 goals: 1) assess vaccine coverage gaps; 2) gather current and non-VFC provider perspectives on the challenges of participating in VFC; and 3) review and analyze the implications of federal policies and how states (including Arizona) interpret and implement those policies.
OMNI’s report will also have policy and operational recommendations for how ADHS can make better decisions and inform leadership changes that, if implemented, could stop, and potentially reverse the decline in provider VFC participation.
While OMNI’s report hasn’t been publicly published yet, the principal investigator was on hand at the meeting to present some of their results.
I took screen shots of the PowerPoint slides presented last week (which had insightful findings about how ADHS can improve provider VFC participation). I’ve decided not to publicly disclose that content until after the full OMNI report is released to give ADHS senior leadership an opportunity to digest the findings and prepare & execute policy and/or staffing changes to address the report’s findings & recommendations.
Related: Righting Arizona’s ‘Vaccines for Children’ Ship
Childhood Vaccination Rates Continue to Drop In the 2021-2022 School Year
Note: CDC’s VFC State Jurisdiction Operational Guide. provides key direction to ADHS regarding what kind of restitution they can impose and what criteria they need to consider before punishing VFC providers. One of the chapters in the Operational Guide states that: “CDC recommends awardees establish a restitution policy for federal vaccine doses (VFC and 317) that are lost due to provider negligence”. Further, it states that: “Vaccine restitution is the replacement of vaccine doses that were lost due to provider negligence. Restitution criteria are at the discretion of awardees.”
“Awardee restitution policies must state that providers are to replace vaccine on a dose-for-dose basis. This allows the restoration of doses to the VFC-entitled children for whom they are intended. Deviation from this method (e.g., purchasing equipment) may be considered if there are extenuating circumstances for an individual provider location.”
ADHS should immediately modify their vaccine restitution policy ’ Restitution policy should:
- Identify examples of typical situations that may require restitution.
- Set reasonable loss thresholds for when restitution is required.
- Consider the size of loss, number of previous incidents involving the provider, and the provider location’s response to education and corrective action plans when determining loss thresholds or doses to be replaced.
The Operational Guide is clear that financial penalties aren’t an appropriate way to punish practices. Indeed, anything besides replacing doses requires ADHS to: “… submit written justification to VFC@cdc.gov and receive CDC approval prior to allowing restitution using any method other than dose-for-dose replacement.”
Recommendations
- Immediately suspend assessment of vaccine restitution penalties pending the development of a new ADHS Restitution Policy. Make sure that remaining VFC providers are informed about the suspension of restitution penalties pending development of a new policy to prevent even more providers from bolting.
- Develop a new Restitution policy after getting input from providers including the county health departments.
